printreg, November, 2003
ANSI Standard May Not Be Enough For Eyewash/Shower Locations

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From: Gary Jones( )
Date: Sun, 16 Nov 2003 22:49:27

To All:

FYI - From National Safety Council's November 2003 Business and Industry Newsletter

Is Meeting ANSI Z358.1-1981 Enough For Eyewash/Shower Stations?

A case study from an OSHA Review Commission Case on travel distance to eyewashes and safety showers asks the question, is 10 seconds and/or 75 feet close enough for everyone?

The Secretary alleged a serious violation of 29 C.F.R. 1910.151(c) for failure to provide suitable facilities for quick drenching or flushing of the eyes and body for employees who changed 100-pound chlorine cylinders in the chlorine storage and pot line areas of the foundry. The standard provides: 1910.151 Medical services and first aid. (c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

The facts are largely undisputed. Every three days, employees replaced empty chlorine gas cylinders with full ones in the cited areas. Employees wore full-face respirators and rubber gloves while performing this work but did not wear protection for the neck, arms, and legs. In recommending the citation, OSHA consulted the MSDS for chlorine, which describes chlorine as a corrosive chemical. The MSDS also indicates that when chlorine comes into contact with a person's skin, the first aid requirement is to immediately flush with water for at least 15 minutes.

OSHA testified that if chlorine were to come into contact with an employee's eyes, it could cause severe corneal damage, and if it contacted skin, it could cause severe burns and tissue damage. OSHA stated that an acceptable distance for the location of a quick drenching or flushing area in the cited circumstances would be within ten feet. Facilities for drenching and flushing were located within the company's foundry but could not be seen from the cited work areas.

The company's safety director testified that, after the inspection, she took measurements showing that the nearest facilities were located 70 to 75 feet from the cited areas. According to the company, the safety manager was able to walk from the cited areas to the existing facilities within 10 seconds. They believed that as a rule of thumb an emergency drenching or flushing area had to be located within 100 fee of a given work area.

During testimony, counsel for the company introduced into evidence a copy of the American National Standard for Emergency Eyewash and Shower Equipment, ANSI Z358.1-1981, which had been provided to the company by OSHA. Section 5.4.4 of the ANSI standard states that eyewash units shall be in accessible locations that require no more than 10 seconds to reach and should be within a travel distance no greater than 30.5 meters (100 feet) from the hazard.

An explanatory note in this provision recommends that for strong acids or caustics, the eyewash facility should be immediately adjacent to or within 3 meters [10 feet] of the hazard. The company acknowledged that chlorine gas was a strong acid when it came into contact with skin or eyes.

The Commission has long held that section 1910.151(c) does not require water facilities to be within any specific linear distance. Gibson Discount Center, Store No. 15, 6 BNA OSHC 1526, 1527, 1978 CCH OSHD 22,669, p. 27,357 (No. 14657, 1978). Rather, the issue of whether an employer's facilities are adequate to comply with the standard depends on the particular circumstances present at the workplace, including the nature and amount of corrosive materials to which employees are exposed, the configuration of the work area, and the distance between the spot where corrosive chemicals are used and the drenching facilities.

Violation depends on totality of the circumstances, including the nature and amount of the substance in question. In affirming the violation, the judge concluded that a facility located 70 to 75 feet from the cited areas did not meet the standard’s requirement that it be located within the work area for immediate emergency use. Applying the factors set forth in Bridgeport Brass to this case, the judge found that a violation was established based on the highly corrosive nature of the chlorine gas to which employees were exposed; the inability to view existing drenching facilities from the work area; and the 75 foot distance between the work area and the existing drenching facilities.

We have examined the record in its entirety, considered the arguments of the parties on review, and conclude that the judge's decision is supported by the evidence and applicable legal precedent. Accordingly, the Review Commission affirms the violation.

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